20110527Application.pdf

~~~OUNTAIN
RECEIVED
May 27,2011 ioti HAY 27 AM 10: 29
201 South Main, Suite 2300
Salt Lake City. Utah 84111
VI OVERNIGHT DELIVRY t"'
\.:!
Jean D. Jewell
Commssion Secreta
Idaho Public Utilities Commssion
472 W. Washington
Boise,ID 83702
Re: Case No. P AC-E-II-12
In the Matter of the Application of Rocky Mounta Power for Approval of Changes
to its Electrc Service Schedules and a Price Increase of $32.7 Milion, or
Approximately 15.0 Percent
Dear Ms. Jewell:
Please find enclosed for filing an original and nine copies of Rocky Mountain Power's
Application in the above-referenced mattr, along with nie copies ofPacifiCorp's direct
testimony and exhbits. Also enclosed is a CD contag the Application, sumar of
testimony, testimony and exhbits, customer notice and press release; and a confdential CD
containg confdential testimony and exhbits. To the attention of the Cour Reporter is a
paper copy of all documents along with a CD contanig all testimony and exhbits in their
original formats.
All formal correspondence and regarding ths Application should be addrssed to:
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Uta 84111
Telephone: [phone]
Fax: [phone]
Email: ted.weston~pacificorp.com
Danel E. Solander
Rocky Mounta Power
201 South Main Street, Suite 2300
Salt Lake City, Uta 84111
Telephone: [phone]
Fax: [phone]
Email: daniei.solander~pacificorp.com
Communcations regarding discovery matters, including data requests issued to Rocky
Mounta Power, should be addressed to the followig:
By E-mal (preferred):datarequestißacificorp.com
By reguar mail:Data Request Response Center
PacifiCorp
825 NE Multnoma St., Suite 2000
Portland, OR 97232
Mark C. Moench, Pro Hac Vice
Danel E. Solander, Pro Hac Vice
Rocky Mountan Power
201 South Mai Street, Suite 2300
Salt Lake City, Uta 84111
Telephone: [phone]
Email: mark.moench~pacificorp.com
daniel.solander~pacificorp.com
RECEIVED
201' HAY 27 AM 10: 29
Paul J. Hickey, Pro Hac Vice
Hickey & Evans, LLP
1800 Carey Avenue, Suite 700
P.O. Box 467
Cheyenne, vr 82003-0467
Telephone No. 307-634-1525
Facsimile No. 307-638-7335
Email: phickey~hickeyevans.com
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUNAI POWER FOR
APPROVAL OF CHAGES TO ITS
ELECTRIC SERVICE SCHEDULES
AN A PRICE INCREASE OF $32.7
MILLION, OR APPROXITELY
15.0 PERCENT
)
)
)
)
)
)
CASE NO. PAC-E-1l-12
APPLICATION OF
ROCKY MOUNTAI POWER
Rocky Mounta Power, a division of PacifiCorp ("Rocky Mountan Power" or the
"Company") hereby applies to the Idao Public Utilities Commssion ("Commission") for
approval of proposed changes to the Company's electrc service schedules submitted
herewith. In support of ths Application, Rocky Mountain Power states as follows:
1. Rocky Mounta Power is authorized to do and is doing business in the state
of Idao. The Company provides retail electrc servce to approximately 72,400 customers in
APPLICATION OF
ROCKY MOUNTAI POWER
Page 1
the stte of Idaho and is subject to the jursdiction of the Commssion. Rocky Mounta
Power is a public utility in the state of Idao pursuat to Idaho Code § 61-129.
2. Communcations regarding ths Application should be addressed to:
Ted Weston
Danel E. Solander
201 South Mai Suite 2300
Salt Lae City, Uta 84111
Telephone: [phone]
Fax: [phone]
Email: ted.weston~pacificorp.com
dael.solander~pacificorp.com
and to:
Paul J. Hickey, Pro Hac Vice
Hickey & Evan, LLP
1800 Cary Avenue, Suite 700
P.O. Box 467
Cheyenne, vr 82003-0467
Telephone No. 307-634-1525
Facsimile No. 307-638-7335
Email: phickey~hickeyevans.com
and to:
D. Mattew Moscon
Stoel Rives LLP
201 South Main Stret, Suite 1100
Salt Lake City, UT 84111
Phone: [phone]
Fax: [phone]
Emal: mmoscon~stoei.com
APPLICATION OF
ROCKY MOUNTAI POWER
Page 2
Idaho Public Utilities Commssion
May 27, 2010
Page 2
Informal inquies may be directed to Ted Weston, Idaho Reguatory Manager at (801) 220-
2963.
Very try yours,
Gr v. ~ /rvJ
Jeffey K. Larsen
Vice President, Regulation
cc: Service List
Enclosurs
In addition, the Compay respectfly requests that all data requests regardig ths
mattr be addressed to one or more of the followig:
Bye-mail (preferred)
By reguar mal
dataequest~pacificorp.com
Data Request Response Center
PacifiCorp
825 NE Multnomah Suite 2000
Portland, OR 97232
3. Rocky Mountan Power's proposed revise taff schedules, which are fied
with ths Application, would result in a net increase of $32.7 millon, or 15.0 percent on
average, in prices for the Company's Idao retal customers. The revised taff schedules
reflect a proposed effective date of June 27, 2011.
4. The Company's requested rate increase is based on a test year that covers the
period of Janua 1, 2010, though December 31, 2010, with known and measurble
adjustments though calendar year 2011. The Company expects to ear a retu on equity
("ROE") of 5.3 percent durng the test period, which is signficantly below the Company's
curently authorized retu, the retus authorized for other Idaho investor-owned utilities,
and the 10.5 percent ROE supported by the Company's testimony filed with this Application.
Without the requested increase in revenues, it will be increasingly diffcult for the Compay
to mainta its utilty inftrctue and continue to provide adequate and effcient service to
its Idao customers.
5. The major factor for the requested revenue increase is an increase in net
power costs, which represents approximately 51 percent of the requested additiona revenue.
Tota Company net power costs have increased $287 millon above the costs curntly
included in customers' rates. The increase is drven by a rage of factors, includig increased
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 3
load, chages in the Company's portolio of wholesae purchase and sales contrcts, and
increases in coal costs.
6. Capital additions are also a signficant factor in the need for an increase in
revenues, representing approximately 31 percent of the increase.
7. Incrementa operating costs associated with added generation and
envionmenta facilties reuire an increase in operation and maitenace expense to ensure
proper plant operations, and represent approximtely 17 percent of the increase. Ths
Application includes the investments, costs, and benefits of the Company's activities durg
the test period, and reflects other changes in costs durng that period.
8. Rocky Mounta Power's direct case consists of the testimony and exhbits of
fouren witnesses. Below is a brief sumar of their testiony.
(a) A. Richad Walje, President, Rocky Mountan Power, will present an
overview of the Company's justification for its cas, identify the major capita
investment the Company is makng to serve its customers, the cost control
efforts the Company is undertng to mimize rate impact on customers, and
introduce other witnesses.
(b) Steven R. McDougal, Director, Revenue Requiement, will present the
Company's overall revenue requiement based on the forecasted results of
operations for the test year. In addition, Mr. McDougal will explai why the
test year tht begins on Janua 1,2010, and ends on December 31, 2010, with
known and measurble adjustents though calenda year 2011 best reflects
the conditions tht the Company expects to expeence in the rate effective
period.
APPLICATION OF
ROCKY MOUNTAI POWER
Page 4
(c) Bruce N. Wiliams, Vice President and Treasurer, will testify in support of the
Company's cost of debt, preferred stock and capital sttu.
(d) Samuel C. Hadaway, FINANCO, Inc., will testify in support of the
Company's requested rate of retu on equity. He will also describe the
signficant chages in the capita markets that afect Rocky Mounta Power.
Dr. Hadway's anysis suggests a rate of retu on equity for the Company of
10.5 percent.
(e) Cathy S. Woollums, Senior Vice President of Environmenta Servces and
chief environmenta counsel for MidAerican Energy Holdings Company,
will testify to the prudence of the Company's pollution control expenditues
for coal-fired power generation plants.
(f) Chad A. Teply, Vice President of Resoure Development and Constrction for
PacifiCorp Energy, will testify regardig the prudence of generation plant
capita investments being placed in servce and associated incrementa
operation and maitenance costs durng the test period.
(g) Darell T. Gerrard, Vice President of Tranmission Plang, will explain and
support the major capita investments in the Company's trsmission system.
He explais the priar drvers creating the need for these projects, and
describes the benefits to customers and the electrcal system overall. Mr.
Gerrard will also provide additional informtion supporting rate recovery of
the entie investment in the Populus to Term line.
(h) Grgory N. Duvall, Director of Net Power Costs, will testfy regarding the
Company's net power costs, describe the key changes that occur in the test
APPLICATION OF
ROCKY MOUNTAI POWER
PageS
period, and sponsor the GRI model that support the net power costs in ths
application. In addition, Mr. Duvall will addresses the specific issues related
to the GRI model described in the Commssion's Orer No. 32196 in the
Company's 2010 genera rate case.
(i) Cindy A. Crae, Vice President, Interest Mig Company and Fuel
Resources for PacifiCorp Energy, will explai the Company's overall
approach to providig the coal supply for the Company's coal plants.
G) Erich D. Wilson, Director, Human Resources, will provide an overview of the
compensation and benefit plan provided to employees at the Company and
support the costs related to these areas included in the test period.
(k) Paul H. Clements, OrgintorlPower Marketer for PacifiCorp Energy, will
sumarze the statu of the Company's efforts to enter into a long-term
contract with Monsto for curlment products and offer an update to the
curlment valuation based on curent conditions.
(1) Barbar A. Coughin, Director of Customer and Reguatory Liaison, will
sumarze the progress the Compay has made workig with Commssion
sta on the miscellaneous consumer and customer serice issues and present
the Company's position on low income weatherization assistace as directed
by the Commssion in Case No. PAC-E-IO-07.
(m) C. Crag Paice, regulatory consultat in the pricing and cost of service
deparent will present the Company's class cost of seice study.
APPLICATION OF
ROCKY MOUNTAI POWER
Page 6
(n) Willam R. Grffth, director of pricing, cost of service, and reguatory
operations, will present the Company's rate spread and rate design proposals
tht determe the prices customers will see.
6. Rocky Mounta Power is notifyg its cusomers of ths Application by
means of a press release sent to local meda organizations, bil insert included in customer
bils over the coure of a biling cycle, and, in some cases, persona contact with customers or
their representatives. In addition, copies of ths Application will be made available for
review at the Company's local offces in its Idao serce terrtory.
7. In accordace with Commission Rule 121(e), (f), and (g) Rocky Mountain
Power represents tht the Application provides testimony with supportg exhbits, along
with any associated workpapers or documentation showig how test year data was adjusted.
In addition, cost of capita, revenue requiment, net power costs, cost of servce and rate
design studies and associated models are included with ths Application. The Company
respectfly requests that the Commission requie interenig paries to provide any models
and workpapers used to prepare their positions concurently with the filing of testimony in
ths Case. In addition, the Company requests tht intervenig paries be required to comply
with identical discovery timelines imposed by the Commssion in any scheduling or
procedural orders in this Cas. Unless otherwse ordered by the Commssion, in accordace
with Commssion Rule 63, the Company will serve discovery responses on any intervening
paries only by electrnic maiL.
8. The Company respectfuly submits that Commssion approval of Rocky
Mountan Power's Application, includig the approval and implementation of the proposed
electrc service schedules as fied, is in the public interest. In accordace with Commission
APPLICATION OF
ROCKY MOUNTAI POWER
Page 7
Rule 121(d), Rocky Mounta Power represents that it stads ready for immediate
consideration of ths Application.
WHREFORE, Rocky Mounta Power respectfly request that the Commssion
issue a fial order approving the Company's proposed electrc serce schedules effective
June 27, 2011.
DATED this 27thth day of May, 2011.
Respectfly submitted,
BY~
Mark C. Moench
Paul J. Hickey
Danel E. Solander
Attorneys for Rocky Mounta Power
APPLICATION OF
ROCKY MOUNTAI POWER
Page 8
RECEIVED
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSIONlDlI HAY 27 AM 10: 30
IN THE MATTER OF THE )
APPLICATION OF ROCKY )
MOUNTAIN POWER FOR )
APPROVAL OF CHANGES TO ITS )
ELECTRIC SERVICE SCHEDULES )
AND A PRICE INCREASE OF $32.7 )
MILLION, OR APPROXIMATELY
15.0 PERCENT
CASE NO. PAC-E-ll-12
APPLICATION OF
ROCKY MOUNTAIN POWER
AFFIDAVIT OF DANIEL E. SOLANDER
I, Daniel E. Sol ander, being duly sworn on oath, depose and say:
1. I am an attorney representing Rocky Mountain Power in the above-captioned
proceeding.
2. The testimony of Gregory N. Duvall, Cindy A. Crane and Paul H. Clements, and
Exhibits: 3, 22, 23, 24, 2S, 26, 27, 32, and 37 filed with the Application, contain
confidential information and trade secrets as defined in Idaho Code § 9-340 et
seq. and § 48-801 et seq. that may jeopardize the interests of Rocky Mountain
Power and its customers and could cause economic or other har if it were
disclosed.
3. On information and belief, the Company understands that cerin data related to
Monsanto's rate as referenced in the testimony of Paul Clements may have
entered the public domain by virte of Monsanto's own disclosure of such
information. Notwithstanding this understanding, Rocky Mountain Power is
treating this information as Confidential until Monsanto and the Company discuss
this issue fuher.
4. Rocky Mountain Power requests that the Commission consider these documents
Confidential and protect them from public disclosure.
Furter affant sayeth not./\J~~~
Daniel E. S¿lander
State of Oregon )
nl) i i I J1J1 ift1A1 ) ssCounty of ~JJ\
On theZt? Day of ~' 201 1, the above appea before ~ and signed this afdavit.~ ~~I\
Notar Public_ OFRCIA SEA
: ': CAMEN MARIE BOUGHN
\. ... NOTAR PUBUC-REGON
COMMISSION NO. 441983
MY COMMISSION EXRES AUGUST 17, 2013
CERTIFICATE OF SERVICE RECËIVED
I hereby certfy that on ths 27th day of May, 2011, I caused to be served, via --127 AM '0: 30
delivery, a tre and correct copy of Rocky Mountain Power's Application for Ap~~~y~!", ,......!
of ch~ges to its electrc se~ice schedules and a price inc~ease of$32.7 mil¥fftlfDr~~;¿d1,i¡\¡¡~g'(\A¡
approximately IS.0 percent in PAC-E-II-12 to the followig: ~Iv"
Eric L. Olsen
Racine, Olson, Nye, Budge & Baiey,
Charered
201 E. Center
P.O. Box 1391
Pocatello, iD 83204-1391
E-Mail: elo~racinelaw.net
Radal C. Budge
Racine, Olson, Nye, Budge & Bailey,
Chaered
201 E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
E-Mail: rcb~racinelaw.net
Tim Buller
Agrium, Inc.
3010 Conda Road
Soda Springs, ID 83276
E-Mail: tbuller~agrum.com
Care Meyer
Coordinator, Admstrtive